Corrective Action Plans

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SECTION III - FINDINGS AND QUESTIONED COSTS – MAJOR FEDERAL AWARD PROGRAMS AUDIT FINDING No. 2025-001: Section 202 Supportive Housing for the Elderly - Capital Advance, ALN 14.157 Recommendation: The Project should implement procedures to ensure that initial and ongoing tenant eligibility documentat...
SECTION III - FINDINGS AND QUESTIONED COSTS – MAJOR FEDERAL AWARD PROGRAMS AUDIT FINDING No. 2025-001: Section 202 Supportive Housing for the Elderly - Capital Advance, ALN 14.157 Recommendation: The Project should implement procedures to ensure that initial and ongoing tenant eligibility documentation is obtained timely and maintained in tenants’ files. Action Taken: Staff training has been provided with additional HUD training inclusive of EIV reporting and tenant file maintenance and included in monthly reporting procedures. If the Oversight Agency for Audit has questions regarding the plan, please call Irene Phillips at 954-835-9200. Sincerely yours, Irene Phillips Irene Phillips CFO
Oversight Agency for Audit, NCSC/USA Housing Development Corporation Two Operating as I.W. Abel Place, respectfully submits the following corrective action plan for the year ended December 31, 2025. Name and address of independent public accounting firm: Bellows Associates, P.A., 5401 N University D...
Oversight Agency for Audit, NCSC/USA Housing Development Corporation Two Operating as I.W. Abel Place, respectfully submits the following corrective action plan for the year ended December 31, 2025. Name and address of independent public accounting firm: Bellows Associates, P.A., 5401 N University Drive, Suite 201, Coral Springs, Florida 33067. Audit period: January 1, 2025 through December 31, 2025 The findings from the December 31, 2025 schedule of findings and questioned costs are discussed below. The findings are numbered consistently with the numbers assigned in the schedule. SECTION III - FINDINGS AND QUESTIONED COSTS – MAJOR FEDERAL AWARD PROGRAMS AUDIT FINDING No. 2025-002: Section 202 Supportive Housing for the Elderly – Capital Advance, ALN 14.157 Recommendation: The Project should comply with HUD regulations for implementing rent increases upon receiving HUD approval, and ensure financial statements are recorded in accordance with GAAP. Action Taken: Staff training has been provided to insure timely applying of gross rent changes and requesting timely move out of tenants on the voucher. This is included in monthly reporting procedures.
FINDING No. 2025-002: Section 202 Supportive Housing for the Elderly, ALN 14.157 Recommendation: The Project should implement procedures for compliance with all HUD regulations and ensure that the supporting documents are prepared in a timely manner. Action Taken: Staff training has been provided re...
FINDING No. 2025-002: Section 202 Supportive Housing for the Elderly, ALN 14.157 Recommendation: The Project should implement procedures for compliance with all HUD regulations and ensure that the supporting documents are prepared in a timely manner. Action Taken: Staff training has been provided regarding UA support and included in monthly reporting procedures. If the Oversight Agency for Audit has questions regarding the plan, please call Irene Phillips at 954-835-9200. Sincerely yours, Irene Phillips, CFO Irene Phillips CFO
Oversight Agency for Audit, NCSC/USA Housing Development Corporation Three, Inc. respectfully submits the following corrective action plan for the year ended December 31, 2025. Name and address of independent public accounting firm: Bellows Associates, P.A., 5401 N University Drive, Suite 201, Coral...
Oversight Agency for Audit, NCSC/USA Housing Development Corporation Three, Inc. respectfully submits the following corrective action plan for the year ended December 31, 2025. Name and address of independent public accounting firm: Bellows Associates, P.A., 5401 N University Drive, Suite 201, Coral Springs, Florida 33067. Audit period: January 1, 2025 through December 31, 2025 The findings from the December 31, 2025 schedule of findings and questioned costs are discussed below. The findings are numbered consistently with the numbers in the schedule. SECTION III – FINDINGS AND QUESTIONED COSTS – MAJOR FEDERAL AWARD PROGRAMS AUDIT FINDING No. 2025-001: Section 202 Supportive Housing for the Elderly, ALN 14.157 Recommendation: The Project should implement procedures to monitor the expiration of HUD required documents to ensure timely preparation and approval. Action Taken: Management is in the process of renewing all management certifications and will provide accountant extra training to monitor.
Funds will not be drawn down until an invoice or proper pay request is received, and purchase order or contract are in hand, and payment is made promptly within no more than three business days. The Schedule of Expenditures of Federal Awards will be reviewed by Management that all funding received a...
Funds will not be drawn down until an invoice or proper pay request is received, and purchase order or contract are in hand, and payment is made promptly within no more than three business days. The Schedule of Expenditures of Federal Awards will be reviewed by Management that all funding received and reported has be fully expensed by the Authority prior to submission on the Hinkle system for audit.
Name of auditee: Fiesta House Senior Housing, Inc. HUD auditee identification number: 122-EE166-WAH-NP Name of audit firm: Dauby O'Connor & Zaleski, LLC Period covered by the audit: Year ended December 31, 2025 CAP prepared by Name: Ana Ponce Position: President Telephone number: 323-231-1104 Curren...
Name of auditee: Fiesta House Senior Housing, Inc. HUD auditee identification number: 122-EE166-WAH-NP Name of audit firm: Dauby O'Connor & Zaleski, LLC Period covered by the audit: Year ended December 31, 2025 CAP prepared by Name: Ana Ponce Position: President Telephone number: 323-231-1104 Current Findings on the Schedule of Findings, Questioned Costs, and Recommendations Statement of condition 2025-003: The Corporation's accounting books and records as submitted for audit included certain accounts which were not presented in accordance with accounting standards generally accepted in the United States of America ("GAAP"). As a result, audit adjustments provided by management were required to present the December 31, 2025 financial statements in accordance with GAAP. Comments on the Finding and Each Recommendation: Management should review the internal controls to ensure that the accounting software allows for timely recording of information and that a timely review of the reconciliations is completed by another accountant not responsible for the month end close. Action(s) taken or planned on the finding: The accounting software provider was changed and a new system to indicate review and approval of the month end closing process is being implemented.
Name of auditee: Fiesta House Senior Housing, Inc. HUD auditee identification number: 122-EE166-WAH-NP Name of audit firm: Dauby O'Connor & Zaleski, LLC Period covered by the audit: Year ended December 31, 2025 CAP prepared by Name: Ana Ponce Position: President Telephone number: 323-231-1104 Curren...
Name of auditee: Fiesta House Senior Housing, Inc. HUD auditee identification number: 122-EE166-WAH-NP Name of audit firm: Dauby O'Connor & Zaleski, LLC Period covered by the audit: Year ended December 31, 2025 CAP prepared by Name: Ana Ponce Position: President Telephone number: 323-231-1104 Current Findings on the Schedule of Findings, Questioned Costs, and Recommendations Statement of condition 2025-002: During the year ended December 31, 2025, management submitted a 9250 to withdraw funds from the reserve for replacements fund that included 16 of the same invoices as a previously approved 9250. The reserve for replacements account was not reimbursed for the duplicate withdrawal. In addition, management submitted and received approval for two proposals for work that was not completed. Comments on the Finding and Each Recommendation: Management should transfer $62,856 from the operating account to the reserve for replacements account. Action(s) taken or planned on the finding: Management will deposit the $62,856 during 2026.
Name of auditee: Fiesta House Senior Housing, Inc. HUD auditee identification number: 122-EE166-WAH-NP Name of audit firm: Dauby O'Connor & Zaleski, LLC Period covered by the audit: Year ended December 31, 2025 CAP prepared by Name: Ana Ponce Position: President Telephone number: 323-231-1104 Curren...
Name of auditee: Fiesta House Senior Housing, Inc. HUD auditee identification number: 122-EE166-WAH-NP Name of audit firm: Dauby O'Connor & Zaleski, LLC Period covered by the audit: Year ended December 31, 2025 CAP prepared by Name: Ana Ponce Position: President Telephone number: 323-231-1104 Current Findings on the Schedule of Findings, Questioned Costs, and Recommendations Statement of condition 2025-001: The Corporation paid entity costs of $6,950 from operating cash. Comments on the Finding and Each Recommendation: The Sponsor should reimburse the Corporation $6,950 or management should request HUD approval for funds to be reimbursed from the reserve for replacement. Action(s) taken or planned on the finding: Management plans to request reimbursement from the reserve for replacement in 2026.
MANAGEMENT AGREES WITH THE FINDING. THE FINANCIAL STATEMENTS WILL BE SUBMITTED TO HUD.
MANAGEMENT AGREES WITH THE FINDING. THE FINANCIAL STATEMENTS WILL BE SUBMITTED TO HUD.
Issue Identified: HUD regulations require that deposits into the Replacement Reserve account be made on a monthly basis. Our agency has historically made annual lump-sum deposits, which is not in compliance with HUD guidelines. Corrective Actions 1. Change in Deposit Frequency Action: Transition fro...
Issue Identified: HUD regulations require that deposits into the Replacement Reserve account be made on a monthly basis. Our agency has historically made annual lump-sum deposits, which is not in compliance with HUD guidelines. Corrective Actions 1. Change in Deposit Frequency Action: Transition from an annual deposit schedule to a monthly deposit schedule in accordance with HUD requirements. Responsible Party: CFO and Accounting Manager Timeline: Effective July 1, 2025 monthly deposits will begin. Verification: Monthly entries and bank confirmations will be reviewed by Accounting. 2. Implementation of Automated Transfers Action: Establish and schedule automated monthly bank transfers to the Replacement Reserve account. Responsible Party: Accounting Manager in collaboration with Banking Institution Timeline: Setup completed by April 15, 2025. First automated transfer on July 1, 2025. Verification: Confirmation of automation setup from the bank and successful execution of first transfer. 3. Monthly Notifications to Fiscal Personnel Action: Create an automated monthly email notification system to alert key fiscal personnel of each deposit, including the amount and confirmation of receipt. Responsible Party: Budget & Reimbursement Manager Timeline: Notification system was remediated by July 1, 2025 Verification: Email log confirming monthly communications sent to fiscal team. Ongoing Monitoring and Compliance The Accounting Manager will review monthly bank statements to verify timely and accurate deposits. The Controller will incorporate verification into monthly closing procedures. Authorization and Approval
2025-001 Section 202 Supportive Housing for the Elderly – Assistance Listing No. 14.517 Recommendation: The auditor recommends that the Company continues to work with HUD to obtain access to the REAC system so that its annual filings can be submitted. Explanation of disagreement with audit finding: ...
2025-001 Section 202 Supportive Housing for the Elderly – Assistance Listing No. 14.517 Recommendation: The auditor recommends that the Company continues to work with HUD to obtain access to the REAC system so that its annual filings can be submitted. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The Company is continuing its efforts to gain access to the REAC system. Name(s) of the contact person(s) responsible for corrective action: Ryan Santarella If the United States Department of Housing and Urban Development has questions regarding this plan, please call Ryan Santarella at 518-567-5053.
2025-001 Section 202 Supportive Housing for the Elderly – Assistance Listing No. 14.517 Recommendation: The auditor recommends that the Company continues to work with HUD to obtain access to the REAC system so that its annual filings can be submitted. Explanation of disagreement with audit finding: ...
2025-001 Section 202 Supportive Housing for the Elderly – Assistance Listing No. 14.517 Recommendation: The auditor recommends that the Company continues to work with HUD to obtain access to the REAC system so that its annual filings can be submitted. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The Company is continuing its efforts to gain access to the REAC system. Name(s) of the contact person(s) responsible for corrective action: Ryan Santarella If the United States Department of Housing and Urban Development has questions regarding this plan, please call Ryan Santarella at 518-567-5053.
Corrective Action Plan - Finding 2025-01: Non-Compliance with Federal Filing Deadlines To prevent a recurrence, Saints Joachim & Anne Nursing & Rehabilitation Center has updated its internal financial reporting calendar to include a "Hard Close" date for all audit activities. Effective immediately, ...
Corrective Action Plan - Finding 2025-01: Non-Compliance with Federal Filing Deadlines To prevent a recurrence, Saints Joachim & Anne Nursing & Rehabilitation Center has updated its internal financial reporting calendar to include a "Hard Close" date for all audit activities. Effective immediately, the Controller is required to initiate the upload of the Data Collection Form and all related financial statements to the Federal Audit Clearinghouse no later than September 15th of each year. This 15-day buffer will ensure that any technical difficulties with the FAC portal or administrative delays do not impact our compliance with federal reporting deadlines. Contact: Christine D'Ottavio, CFO Saints Joachim & Anne Nursing and Rehabilitation Center, 2720 Surf Avenue, Brooklyn, New York 11224 Date: April 28, 2026
Finding #2025-003 – Material Weakness and Material Noncompliance – Allowable Costs. Applicable federal program: National Endowment for the Arts, Promotion of the Arts Grants to Organizations and Individuals, Assistance Listing #45.024, Annual contract periods: 10/01/23 – 09/30/24; 10/01/24 – 09/30/2...
Finding #2025-003 – Material Weakness and Material Noncompliance – Allowable Costs. Applicable federal program: National Endowment for the Arts, Promotion of the Arts Grants to Organizations and Individuals, Assistance Listing #45.024, Annual contract periods: 10/01/23 – 09/30/24; 10/01/24 – 09/30/25. Condition and context: M-AAA failed to submit its indirect cost rate application in 2024, which resulted in a lapse in an approved rate. At the direction of the program officer at the National Endowment for the Arts, M-AAA was directed to use the 10% de minimus rate; however, the billings were not adjusted for the change in indirect rates resulting in overbilling to the federal grants. Recommendation: Re-emphasize internal procedures for review of allowable indirect costs based upon an approved indirect cost rate or election to use 10% de minimus rate. Planned corrective action: M-AAA has elected to use de minimus rate approved by the National Endowment for the Arts (NEA). We reported the overbilling to the NEA and resolved the difference in the indirect costs that had been applied. Responsible officer: Todd Stein, CEO and Charley Young, Finance Director. Estimated completion date: March 2026.
Finding #2025-002 – Material Weakness and Other Noncompliance – Cash Management. Applicable federal program: National Endowment for the Arts, Promotion of the Arts Grants to Organizations and Individuals, Assistance Listing #45.024, Annual contract period: 10/01/22 – 09/30/27. Condition and context:...
Finding #2025-002 – Material Weakness and Other Noncompliance – Cash Management. Applicable federal program: National Endowment for the Arts, Promotion of the Arts Grants to Organizations and Individuals, Assistance Listing #45.024, Annual contract period: 10/01/22 – 09/30/27. Condition and context: The federal contract with M-AAA is a 5-year grant with annual budget periods that end September 30 of each of the years in the contract thru 2027. M-AAA requested advances in the Spring of 2025 when there was uncertainty in the timing of future grant payments. At June 30, 2025, M‑AAA held approximately $578,000 in refundable advances, approximately $368,000 which was spent subsequent to year end for the period of July 1, 2025 to September 30, 2025. Recommendation: Re-emphasize internal procedures to ensure federal funds are not being held for an excess period of time. Planned corrective action: M-AAA was uncertain about the timing of future grant payments and requested advances in April 2025. Because payments to subrecipients were delayed, excess funds remained on hand at fiscal year-end and were distributed in the following fiscal year. With a stronger cash position in the new fiscal year, we have shifted to a reimbursement-based approach for cash requests. Advances will be requested only when grant payments are expected within 30 days and closely monitored to ensure close out. Responsible officer: Todd Stein, CEO and Charley Young, Finance Director. Estimated completion date: December 2025.
Reporting – Financial and Performance Assistance Listing Number 14.251 – Economic Development Initiative, Community Project Funding, and Miscellaneous Grants U.S. Department of Housing and Urban Development (HUD) Federal Award Identification Number(s): B-22-CP-CO-0165 and B-23-CP-CO-0280 Award Year ...
Reporting – Financial and Performance Assistance Listing Number 14.251 – Economic Development Initiative, Community Project Funding, and Miscellaneous Grants U.S. Department of Housing and Urban Development (HUD) Federal Award Identification Number(s): B-22-CP-CO-0165 and B-23-CP-CO-0280 Award Year – 2022 and 2023 Condition: During testing, it was noted that the semiannual performance reports required to be submitted during calendar year 2025 were not submitted by the required deadlines. The reports, which were due in January 2025 and July 2025, were not submitted until September 2025. As a result, the Grantee did not submit required financial and performance reports within the timeframe prescribed by the grant agreement and 2 CFR §§ 200.328 and 200.329. Additionally, management could not provide evidence of review for one of the reports. Planned Corrective Action: Departments that administer grants will establish and maintain a grant tracking process to identify required reporting, due dates, and personnel responsible for the completion and review of the required reporting. This tracking process will be documented and shared with the Controller’s Office. In addition, Departments will maintain documentation of the review and approval of reports as part of the grant documentation. City of Aurora Responsible Party: Stephanie Keiper, Homelessness Division Manager; Matthew Kipp, Manager of Business Services; Tim Sherbondy, Grant Compliance Officer; and Tyra Litzau, Controller Anticipated Completion Date: March 31, 2027
2025-001 – ALN 14.881 – Moving to Work Demonstration Program – Allowable Activities Management acknowledged the finding and will follow the Auditor's recommendations as listed in the Schedule of Findings and Questioned Costs. The Authority has begun taking corrective action to address the matter. Th...
2025-001 – ALN 14.881 – Moving to Work Demonstration Program – Allowable Activities Management acknowledged the finding and will follow the Auditor's recommendations as listed in the Schedule of Findings and Questioned Costs. The Authority has begun taking corrective action to address the matter. The Authority has contacted HUD to obtain guidance on the appropriate method for resolving the balance and ensuring compliance with applicable requirements. Upon receiving HUD's direction, the Authority will implement the necessary corrective measures and take steps to prevent similar issues from occurring in the future. Person Responsible for Correction of Finding: Bonita Schatz, Chief Executive Officer Projected Completion Date: Ongoing work in progress. No completion date can currently be determined.
Finding 2025-001 Allowable Cost Principles and Activities Allowed or Unallowed Significant Deficiency in Internal Control Over Compliance Assistance Listing Number 21.029 While Wabash currently maintains informal procedures for coding and reviewing invoices and payroll records, we recognize the need...
Finding 2025-001 Allowable Cost Principles and Activities Allowed or Unallowed Significant Deficiency in Internal Control Over Compliance Assistance Listing Number 21.029 While Wabash currently maintains informal procedures for coding and reviewing invoices and payroll records, we recognize the need for a formalized, written policy governing expenditures charged to federal awards. To address identified significant deficiency, Wabash implemented a comprehensive written policy as of June 30, 2026. This policy will formalized the coding, review, and reporting processes for all federal expenditures. Key improvements included: • Enhanced Internal Controls: We established a clear segregation of duties to ensure oversight and accuracy. • Timely Reporting: We refined our payroll allocation process. Previously, payroll expenditures were withheld pending budget verification, which occasionally led to reporting delays. New controls will ensure that all expenditures, including payroll, are reported within the required quarterly timeframes. • Monitoring: The Controller will oversee the development of these procedures and remain responsible for ongoing monitoring and compliance. These steps will ensure our financial practices meet federal standards and provide rigorous oversight of project funds. Contact person(s): Cheryl Gaither, Controller Justin Gephart, Chief Operating Officer
SPHA is required to update the obligation and expenditure amounts for each open Capital Fund grant at the beginning of each month. The timing of the monthly update was an administrative error, as it was processed before the voucher request. As recommended, SPHA will ensure that funds designated for ...
SPHA is required to update the obligation and expenditure amounts for each open Capital Fund grant at the beginning of each month. The timing of the monthly update was an administrative error, as it was processed before the voucher request. As recommended, SPHA will ensure that funds designated for operations are obligated when the corresponding funds are drawn. This process will help ensure that future monthly updates accurately reflect the timing of obligations and expenditures.
In late 2025, the Stevens Point Housing Authority (SPHA) transitioned its primary banking relationship from Chase Bank to Associated Bank and obtained a signed depository agreement from Associated Bank. As of December 2025, SPHA no longer utilized Chase Bank for its business banking activities and t...
In late 2025, the Stevens Point Housing Authority (SPHA) transitioned its primary banking relationship from Chase Bank to Associated Bank and obtained a signed depository agreement from Associated Bank. As of December 2025, SPHA no longer utilized Chase Bank for its business banking activities and to receive HUD funds. All primary banking activities and related funds are maintained through Associated Bank. The transfer of funds from the Chase Bank account to the Associated Bank account occurred during the third quarter of 2025 through January 2026 as part of the transition. The Chase account has remained open solely to preserve access to the account and any historical online banking information that may be needed during the completion of the 2025 audit or for other administrative purposes. Following completion and HUD approval of the 2025 audit, SPHA plans to formally close the remaining Chase Bank account.
Finding 2025-001 – Special Tests and Provisions – RAD Replacement Reserve – Significant Deficiency ALN 14.195 Corrective Action Plan: The results of this finding were due to an unintentional calculation error. During the preparation of the reserve activity reconciliation, the individual responsible ...
Finding 2025-001 – Special Tests and Provisions – RAD Replacement Reserve – Significant Deficiency ALN 14.195 Corrective Action Plan: The results of this finding were due to an unintentional calculation error. During the preparation of the reserve activity reconciliation, the individual responsible inadvertently failed to account for withdrawals that had already been approved and processed during the year. As a result, the calculation incorrectly netted deposits and withdrawals, leading to an erroneous additional withdrawal amount. Management has determined that this was an isolated human error rather than a deficiency in policy or intent. To prevent a recurrence, a standardized reconciliation worksheet has been developed and will be completed annually to verify replacement reserve activity and ensure that all future withdrawals are accurately calculated and properly authorized before funds are disbursed. Person Responsible: Jennifer Farmer, Executive Director Anticipated Completion Date: December 31, 2026
2025-001 ALN 14.871 – Housing Voucher Cluster – Eligibility Management acknowledged the finding and will follow the Auditor's recommendations as listed in the Schedule of Findings and Questioned Costs. Person Responsible for Correction of Finding: Ms. Lori Nettles, Interim Executive Director Project...
2025-001 ALN 14.871 – Housing Voucher Cluster – Eligibility Management acknowledged the finding and will follow the Auditor's recommendations as listed in the Schedule of Findings and Questioned Costs. Person Responsible for Correction of Finding: Ms. Lori Nettles, Interim Executive Director Projected Completion Date: December 31, 2026
Finding 2025-007 –Waiting List – Eligibility – Internal Control over Waiting Lists – ALN 14.871 Housing Choice Voucher Program, ALN 14.850 Low Rent Public Housing Program – Noncompliance and Material Weakness Corrective Action Plan: • Preserve a dated copy or system extract of each waiting list at m...
Finding 2025-007 –Waiting List – Eligibility – Internal Control over Waiting Lists – ALN 14.871 Housing Choice Voucher Program, ALN 14.850 Low Rent Public Housing Program – Noncompliance and Material Weakness Corrective Action Plan: • Preserve a dated copy or system extract of each waiting list at material selection and offer points; • Retain applicant rank and preference information; • Document selections; • Establish a sufficient audit trail; • Reconcile written procedures with the Administrative Plan and ACOP; and • Include waiting-list records in the formal retention schedule. Person Responsible: Jennifer Oberlin, Executive Director, with oversight and approval by the Board of Commissioners, where applicable. Anticipated Completion Date: October 30, 2026
Finding 2025-005 – Tenant Files – Eligibility – ALN 14.871 Housing Choice Voucher Program – Noncompliance and Material Weakness Corrective Action Plan: Immediate Corrective Actions are: • Begin targeted quality-control reviews of HCV and public housing files; • Correct missing or incomplete document...
Finding 2025-005 – Tenant Files – Eligibility – ALN 14.871 Housing Choice Voucher Program – Noncompliance and Material Weakness Corrective Action Plan: Immediate Corrective Actions are: • Begin targeted quality-control reviews of HCV and public housing files; • Correct missing or incomplete documentation; • Verify income calculations and deductions; • Confirm citizenship and identity documentation; • Confirm HAP contracts and EIV reports; • Confirm inspections and annual recertifications; • Review lead-based paint disclosures; and document corrective actions. Following the adoption of updated formal policies and procedures – implement long term corrective actions. Long Term: • Establish a formalized, organization-wide QA/QC and Monitoring Framework that includes: o File Reviews o Wait List QC Checklists & Wait List Archive Requirements o IMS/PIC Reporting Controls o Procurement Reviews o Financial Reviews o Internal Audit Checklists o Internal Monitoring Schedule o Corrective Action Tracking • Create a structured monitoring schedule to verify that internal controls continue to operate exactly as designed. • Develop a standardized reporting template to log control exceptions, track communication protocols, and document the successful remediation of identified deficiencies. • Develop standardized onboarding program that incorporates training on core organizational policies, ethical expectations and foundational internal control responsibilities. • Develop Agency-Wide Training Calendar and CE Requirements and Annual Policy Certifications and employ a system to track and archive all. Person Responsible: Jennifer Oberlin, Executive Director, with oversight and approval by the Board of Commissioners, where applicable. Anticipated Completion Date: February 26, 2027
Finding 2025-002 – Policies and Procedures Require Review and Update – ALN 14.871 Housing Choice Voucher Program, ALN 14.850 Low Rent Public Housing, ALN 14.872 Capital Fund Program – Significant Deficiency Corrective Action Plan: Strengthening Board governance, ethical expectations, policy ownershi...
Finding 2025-002 – Policies and Procedures Require Review and Update – ALN 14.871 Housing Choice Voucher Program, ALN 14.850 Low Rent Public Housing, ALN 14.872 Capital Fund Program – Significant Deficiency Corrective Action Plan: Strengthening Board governance, ethical expectations, policy ownership, accountability, and delegated authority. Initial Deliverables • Code of Ethics; • Conflict-of-Interest Policy; • Whistleblower and Reporting Policy; • Delegation of Authority Matrix; • Spending and Approval Authority Matrix; • Signature Authority Matrix; • Policy Development and Review Policy; • Board Governance Framework; • Annual policy acknowledgment process; and • Governance training plan. Standardize the Housing Authority’s major operating processes and reduce reliance on undocumented institutional knowledge. Initial Deliverables • Standard Operating Procedure framework; • Priority SOP inventory; • Housing Choice Voucher processing SOPs; • Public housing occupancy and recertification SOPs; • Waiting-list administration SOPs; • Inspection scheduling and tracking procedures; • Intake and communication procedures; • Position-responsibility matrix; • Updated job descriptions; • Workload assessment; • Staff onboarding procedures; and • Cross-training plan. Improve financial accuracy, safeguarding of assets, segregation of duties, reconciliations, reporting, and management review. Initial Deliverables • Financial Policies and Procedures Manual; • Accounts-payable controls; • Check-run and payment-review procedures; • Payroll approval procedures; • Cash-handling procedures; • Laundry-revenue procedures; • Bank and general-ledger reconciliation procedures; • Monthly and annual financial-review checklist; • Audit-adjustment reconciliation procedures; • Fixed-asset and nonexpendable-equipment inventory procedures; • Capitalization policy update; • Investment policy update; • Creative Housing financial-accounting review; • Inter-entity transaction policy; • Corrective-action plan for questioned costs; • Financial close calendar; • CFO and Executive Director review responsibilities; and • Board financial dashboard. Person Responsible: Jennifer Oberlin, Executive Director, with oversight and approval by the Board of Commissioners, where applicable. Anticipated Completion Date: • Phase 1: Target Date of completion: November 30, 2026 o Implementation and Communication about the Red Flags Ethics Hotline o Identification and creation of needed policies and structural tools o Updating of current policies as needed • Phase 2: Target Date of Completion: April 30, 2027 o Training on new policies/expectations and accountability standards.
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